PRIVACY POLICY

Last Updated: September 3, 2021

 

This Privacy Policy (this “Policy”) describes how SYCAMORE BROKERAGE, LLC (dba LIV Sotheby's International Realty LLC) and our affiliate and subsidiary companies (collectively, “we,” “our,” or “us”) may collect, use, disclose, and otherwise process personal information related to our websites (each, a “Website”), mobile applications (each, an “App”) that display or link to this Policy and our other services, products, and technology solutions and all other ways we may interact with you (collectively, the “Services”). In this Policy, our use of the term “personal information” includes other similar terms under applicable privacy laws—such as “personal data” and “personally identifiable information.” In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual.

 

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

YOUR CONSENT TO THIS POLICY.  By using the Services, you expressly consent to the collection, use and disclosure of information as described in this Policy.

SCOPE OF OUR PRIVACY NOTICE.  This Policy applies to our collection, use, disclosure, and other processing of personal information related to:

 

• the use of our Services that display or link to this Policy;
• former, current, and prospective clients, brokers, independent agents, and customers; and
• other individuals who use our Services, whose personal information we receive related to the Services, or who otherwise interact or communicate with us related to our Services

 

Not covered by this Policy. This privacy notice does not apply to job applicants and candidates who apply for employment with us, or to our employees and non-employee workers.

PERSONAL INFORMATION WE COLLECT.  We may collect or may have collected the following categories of information about you. In some cases, the information we collect may fall within more than one category:

• Identifiers: such as name, contact information, IP address and online identifiers, Social Security number and other government identifiers.
• Customer Records: paper and electronic records containing personal information, which you provide to us in order to access or use our Services, such as name, digital signature, address, telephone number, email and other contact information.
• Characteristics of Protected Classifications: such as disability and health information (e.g., which we may collect in order to, for example, make accommodations available to you at events we host) and other profile information you provide to us.
• Commercial Information: including records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
• Usage Data: internet or other electronic network activity Information including without limitation browsing history, search history, and information regarding an individual's interaction with our Services or an advertisement.
• Geolocation Data: precise location information about a particular individual or device.
• Audio, Video, and Other Electronic Data: audio, electronic, visual, or similar information, such as CCTV images and thermal screenings (e.g., collected from visitors to our offices), photographs and call recordings.
• Employment History: professional or employment-related information.
• Education Information: education information and records.
• Inferences: inferences drawn from any of the above used to create a profile reflecting an individual's preferences, behaviors or other characteristics.

 

WHY WE COLLECT PERSONAL INFORMATION.  In general, we may use and disclose the personal information we collect for the following business and commercial purposes:

 

• Providing support and services
• Analyzing and improving our business
• Personalizing content and experiences
• Advertising, marketing, and promotional purposes
• Securing and protecting our business
• Defending our legal rights
• Auditing, reporting, corporate governance, and internal operations
• Complying with legal obligations

 

 

HOW WE COLLECT PERSONAL INFORMATION.  Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain Services or we may be unable to fully respond to your inquiry.  We may collect personal information directly from individuals, automatically related to the use of the Services, and in some cases, from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third- party services that we use).

 

Information we collect directly. We collect information that you provide to us, such as

• when you create an account, provide contact information, and send other personal information to us;
• when you complete or submit a form through our Services, for example, “Contact Us” or “More Information” forms;
• when you participate in surveys or contests, submit orders or requests, or register for or use our Services, or otherwise contact us;
• information you submit or provide such as real estate searches and preferences, whether you plan on buying or selling real estate, home search criteria, information about financing for the purchase of real estate, and other information related to the purchase or sale of real estate.

 

Information we collect from third parties. We may collect personal information about you and your property from third party sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), from brokers and independent agents of Realogy Holdings Corp. brands, and from other third parties. For example, without limitation:

 

• Social media. If you choose to link, create, or log in to your Services account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with the Services, we may receive personal information about you or your connections from that service. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services.

 

• Real estate professionals. Information that may include, among other things, your name and email address, that you may have given to an independent real estate professional with whom you have a pre-existing relationship. The professional may collect such personal information from you with the sole purpose of pre-populating an account for the Services on your behalf and with your consent. You may choose not to finalize the creation of an account and may opt-out of certain future communications from us by following the instructions in the account creation notification or by contacting us at the email address in this Policy.

 

• Property records. We may collect information about individuals and real estate property through public databases, such as property ownership and tax records maintained by state, local and county agencies.

 

• Affiliates:  We may obtain your contact information and other identifying information from affiliates that you have interacted with.

 

• We collect information from you passively.We collect Internet or other electronic activity passively using tools like browser cookies.

 

WITH WHOM WE SHARE YOUR PERSONAL INFORMATION.  In general, we do not share personal information about you with third parties for such third-parties’ own marketing or advertising purposes. We do share personal information with third parties for other purposes. For example, we share personal information with:

 

• Service providers:We may disclose personal information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, and customer service and support providers.

 

• Subsidiaries and Affiliates:We may share your personal information with our affiliated companies (i.e., companies under common ownership, control or management with us) - use will be subject to this privacy notice.

 

• Third Parties.We may disclose personal information to third parties in order to provide our Services, facilitate your requests, or with your acknowledgement and consent, including with:
  • independent real estate professionals and owners and operators of real estate brokerage companies to enable them to provide services you request through the Services.
  • third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us.
  • the public if you submit to a public part of the Services, such as comments, social media posts, or other features viewable by the public or generally by registered users of the Services.
  • third parties with whom you choose to let us share information, for example other apps or websites that integrate with the Services, or those with Services with which we integrate.
  • third parties we work with to provide you with more personalized content and ads, and to track the effectiveness of campaigns.

 

• Business transfers:We may disclose or transfer personal information as part of any actual or contemplated merger, sale, and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.

 

• Legally required:We may disclose personal information if we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).

 

• Protect our rights:We may disclose personal information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and to protect the rights, property, or safety of us, our clients and customers or others.

 

Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics, and other purposes.

 

COOKIES, TRACKING, AND ANALYTICS.  Our Services may use first party and third-party cookies, pixel tags, plugins, and other tools to gather device, usage and browsing information when users visit our Services. For instance, when you visit our Services, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you select on the Services, as well as date and time stamps associates with your activities on our Services.  We use the information for security purposes, to facilitate navigation, to personalize and improve your experience while using the Services, to improve and measure our advertising campaigns and to better reach users with relevant advertising both on our Services and on third party websites. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

 

Cookies. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the websites, pages visited, language preferences, and other anonymous traffic data. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Service.

 

• Essential cookiesare essential, as they enable you to move around the Service and use its features. Without these cookies we could not, for example, authenticate your login or remember that you are logged-in as you move through the Service.

 

• Functionality cookiesallow us to remember choices you make (such as the region you're in) and tailor the Service to provide enhanced features and content for you. For instance, they can be used to remember your login details or remember your nickname when you next login. They may also be used to provide services you've requested, for example leaving a comment on the Service.

 

 

• Analytics & performances cookiescollect information about how the Service is used, for example which pages users visit most often and if any error messages are displayed on certain pages. Information collected using these cookies is used to monitor activity on the Service and understand how it is being used.

 

If you have disabled one or more cookies, we may still use information collected from cookies before your disabled preference was set. However, we will stop using the disabled cookie to collect any further information.  To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org.

 

Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things, track the actions of users of the Websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates. We and our service providers may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, track whether our emails are forwarded, and conduct analytics.

 

Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.

 

Third party analytics tools. Our Websites use automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google's practices by going to www.google.com/policies/privacy/partners/, and you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

 

INTEREST-BASED ADVERTISING.  On some of our Websites, we may work with third-party ad networks, analytics companies, measurement services and others (“third-party ad companies”) to display advertising on our Services and to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags and other tools to collect information on our Websites (and on third-party sites and services), such as browsing history, IP address, device ID, cookie and advertising IDs, and other identifiers, general location information and, with your consent, your device's geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.  You can manage how your preferences regarding third party ad company cookies set by this Service by reading the cookie discussion above.  Please also see the cookie discussion above for information about the third parties we may work with to display targeted ads on third-party sites and to measure the success of our marketing and campaigns. You may also obtain more information about targeted or “interest-based advertising” and opt-out of many ad networks at the industry websites below:

• Canada: youradchoices.ca
• EU: youronlinechoices.eu
• S.: www.aboutads.info

 

SOCIAL FEATURES AND THIRD PARTY PLUG INS.  The Services may integrate with social sharing features and other related tools which let you log in to the Services or share actions you take on the Services. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. We do not receive or store passwords to your third-party social media accounts in this context.

 

YOUR RIGHTS AND CHOICES. 

 

Marketing. You may opt out from receiving marketing-related communications from us on a going-forward basis by contacting us or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

 

Cookies and similar technologies. Please review your browser or device settings for certain cookies and see above to exercise certain choices regarding cookies.

 

Deactivation. You can deactivate your account at any time by contacting us at the email address at the bottom of this page. However, you will not be able to access many of the services to deactivate your account. Please note that even if you request deactivation of your account, it may take some time to fulfill this request.

 

Responding to Requests. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

 

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION.  The Services are hosted on servers located in the United States. Note that some countries may not provide the same level of data protection as your home country. If you are located, for example, in European Economic Area or Switzerland (collectively, “EEA”), your personal information will be transferred to the United States and possibly to other jurisdictions (e.g., to the location of a property for which you have requested information), which may not provide the same level of protection under your local data protection laws. In such cases, we rely on suitable personal information transfer safeguards. You may have the right to request a copy or information about those safeguards by contacting us as detailed below.

 

SECURITY.  We use technical, administrative, and physical controls in place to help protect personal information from unauthorized access, use, and disclosure. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable. In the event that the security of your account has been compromised, please immediately notify us in accordance with “Contact Us” paragraph below.

 

CHILDREN.  The Services are not intended or directed to children under the age of 16, and we do not knowingly collect any personal information, or knowingly track the use of our Services, from children. If we have actual knowledge that personal information about a child under 16 years old has been collected, then we will take appropriate steps to try and delete such personal information.

 

CALIFORNIA PRIVACY RIGHTS.  Under the California Consumer Privacy Act (“CCPA”), California residents have certain rights regarding the personal information that businesses have about them. This includes the right to notice, access and/or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.

 

Right to Notice. You have the right to be properly notified of the following:

 

• Personal Information We Collect: Please review the section of this Privacy Policy titled Personal Information We Collect for more information about the personal information we collected about you in the past 12 months.

 

• Why We Collect Personal Information: Please review the section of this Privacy Policy titled Why We Collect Personal Information for more information on why we collect personal information about you in the past 12 months.

 

• How We Collect Personal Information: Please review the section of this Privacy Policy titled How We Collect Personal Information for more information on how we collect personal information about you in the past 12 months.

 

• With Whom We Share Your Personal Information: Please review the section of this Privacy Policy titled With Whom We Share Your Personal Information for more information on how we share personal information about you in the past 12 months.

 

Right to Access Your Information: You have the right to request the following covering the 12 months immediately preceding your request:

 

• The specific pieces of personal information we have collected about you
• The categories of personal information that we have collected about you
• The categories of sources from which we collected the personal information
• The purpose for collecting or selling the personal information
• The categories of personal information that we have disclosed about you, the purpose for disclosing such personal information and the categories of third parties with whom we disclosed such personal information
• The categories of personal information that we have sold about you, as well as the categories of third parties to whom we sold such personal information

 

Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual.

 

Right to Deletion: You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfil a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.

 

How to Exercise Your Access and Delete Rights: To exercise your access and delete rights as described above, please submit a verifiable consumer request to us by calling us at (303) 893.3200 or by emailing us at ccparequest@livsothebysrealty.com.

 

Verifiable Consumer Requests: Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access to your personal information twice within a 12-month period. The verifiable consumer request must: 1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person; and 2) Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request to exercise your access and/or deletion rights if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format: We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding the date we receive the verifiable consumer request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For access requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Right to Opt-Out of Sale: While we do not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We support the CCPA and wish to provide you with control over how your personal information is collected and shared. If you would like to exercise your right to request opt-out of sale, please submit a request to ccparequest@livsothebysrealty.com.

 

Right to Non-Discrimination: We will not discriminate against you (e.g., through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the California rights afforded to you. 

 

Complaints. In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your personal information. We ask that you kindly contact us at (303) 893.3200 or by emailing us at ccparequest@livsothebysrealty.com., so that we have an opportunity to resolve your complaint.

 

Do Not Track.  Some internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals.  Since uniform signals have not been adopted, we do not current process or respond to “Do Not Track” or “DNT” signals.

 

California’s Shine the Light law. California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to request more information under the California Shine the Light law, you can email us at ccparequest@livsothebysrealty.com.

 

THIRD-PARTY WEBSITES.  The Services may contain links to third-party services. We do not own, operate, or control the websites of third-parties, including those of independently owned and operated franchisees. Accordingly, this Policy does not apply to any services maintained or operated by third-parties. When you click on those links, you will go to a third-party website where you will be subject to that service's privacy policy or similar statement and terms of use, and we encourage you to read that policy statement. We are not responsible for the privacy practices of other services, and we expressly disclaim any liability for their actions, including actions related to the use and disclosure of personal information by those third parties.

 

CHANGES TO THIS POLICY.  We may amend this Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process personal information, we will prominently post a notice regarding such change on the Services. Any material changes to this Policy will be effective 10 days after our posting of the updated Notice or as otherwise required by applicable law. Where required to do so by law, we may seek your prior consent to any material changes we make to this Policy.

 

CONTACT US.  If you have any questions or concerns about this Policy, please use the following contact information:

• Email: ccparequest@livsothebysrealty.com
• Mailing address: 100 St. Paul St., Suite 200, Denver CO 80206 Attn: Data Privacy
• Phone number: (303) 893.3200